10 Aug Cosmetic Manufacturers and PPWR: What Cosmetic Brands Need to Know
Cosmetic manufacturers and PPWR: What cosmetic brands need to know
For cosmetic brands working with a cosmetic manufacturer, PPWR requirements are becoming an important consideration when placing products on the European Union market. The new EU Packaging and Packaging Waste Regulation introduces important requirements related to packaging sustainability, recyclability, minimisation, labelling and technical documentation.
These requirements are relevant to companies operating within Europe, as well as brands based in other markets that sell or plan to sell their products in the EU.
Working with a cosmetic manufacturer prepared for PPWR requirements can help simplify packaging information management, supplier coordination and the development of new products for the European market.
At Cosmewax, we develop and manufacture cosmetics for brands and retailers across international markets, supporting our customers throughout product development and manufacturing while helping manage information related to the packaging used in the products we manufacture.
What is the PPWR and how does it affect the cosmetics industry?
The Packaging and Packaging Waste Regulation (PPWR), officially Regulation (EU) 2025/40, establishes a new European regulatory framework for packaging and packaging waste.
Its objective is to reduce the environmental impact of packaging and accelerate the transition towards a more circular economy.
The regulation introduces requirements covering areas such as:
- Packaging recyclability.
- Packaging weight and volume minimisation.
- Recycled content in certain plastic packaging.
- Packaging composition and substances of concern.
- Harmonised packaging labelling.
- Technical documentation and conformity assessment.
- Packaging waste prevention and reduction.
The PPWR will therefore have a direct impact on cosmetic packaging and should increasingly be considered both when reviewing existing products and when developing new launches.
Does the PPWR apply to companies outside the European Union?
The PPWR applies to packaging placed on the European Union market. This means that its impact is not limited to companies headquartered within the EU.
Cosmetic companies based in markets such as the United Kingdom or United States, for example, may also need to consider PPWR requirements when their products are placed on the EU market.
The regulation establishes obligations for different economic operators within the supply chain, including manufacturers, importers and distributors. The specific responsibilities of each company will therefore depend on its role in placing the product and packaging on the European market.
For brands operating internationally, this makes coordination between regulatory, procurement, product development, manufacturing and packaging suppliers increasingly important.
PPWR timeline: key dates for cosmetic brands
The different PPWR requirements will be introduced progressively. These are some of the key dates cosmetic companies should keep in mind.
11 February 2025: entry into force
Regulation (EU) 2025/40 officially entered into force on 11 February 2025.
12 August 2026: general application
The PPWR generally applies from 12 August 2026, although certain requirements have their own specific implementation dates.
Cosmetic brands, retailers, manufacturers and packaging suppliers should therefore identify which obligations apply to their packaging and their specific role within the supply chain.
From 2028: harmonised packaging labelling
The PPWR introduces harmonised labelling requirements designed to help consumers correctly sort packaging waste.
The relevant requirements are scheduled to apply from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later.
2030: recyclability, recycled content and packaging minimisation
2030 represents another important PPWR milestone.
Requirements concerning packaging recyclability and minimum recycled content for certain plastic packaging become particularly relevant from 2030.
Packaging will also need to be designed so that its weight and volume are reduced to the minimum necessary to maintain its functionality.
For cosmetic brands developing products today, these future requirements should increasingly be considered when making packaging design and material decisions.
How does the PPWR affect cosmetic brands and retailers?
One important aspect of the PPWR is that compliance is not simply a matter for the company physically producing the packaging.
The regulation establishes responsibilities for different economic operators throughout the supply chain.
Each company will therefore need to determine its role and the corresponding obligations based on how its products and packaging are placed on the EU market.
For brands and retailers working with a cosmetic contract manufacturer, having a supply chain capable of providing and managing the relevant packaging information will become increasingly important.
Packaging documentation will be key to PPWR compliance
Adapting to the PPWR is not simply about replacing materials or redesigning cosmetic packaging.
One of the major challenges will be obtaining and managing the technical information and documentation needed to demonstrate packaging conformity with the applicable requirements.
Depending on the product, several packaging components may need to be considered:
- Primary containers.
- Caps and closures.
- Pumps and dispensers.
- Labels.
- Cartons.
- Protective films.
- Grouped packaging.
- Transport packaging.
This information may come from multiple suppliers, sometimes located in different countries, making effective coordination throughout the supply chain essential.
The PPWR also establishes obligations concerning the information and documentation that suppliers must provide to support packaging conformity.
What documentation does the PPWR require?
Regulation (EU) 2025/40 introduces requirements related to packaging conformity assessment and technical documentation.
Manufacturers subject to the relevant obligations must be able to demonstrate that packaging complies with the applicable requirements and draw up the corresponding EU Declaration of Conformity.
Technical documentation must contain sufficient information to assess packaging conformity and must be retained for the periods established by the regulation.
For cosmetic companies, this reinforces the importance of packaging traceability, supplier documentation and structured information management.
Why work with a cosmetic manufacturer for PPWR compliance?
Choosing the right cosmetic manufacturer for PPWR compliance can help brands manage the growing complexity of packaging requirements in the European market.
Working with a cosmetic manufacturer that has structured processes for managing packaging information can help with:
- Collecting documentation from packaging suppliers.
- Identifying individual packaging components.
- Improving traceability of technical information.
- Coordinating with packaging suppliers.
- Considering PPWR requirements during new product development.
- Anticipating potential packaging changes.
- Reducing potential issues during future product launches.
For procurement, packaging, product development and regulatory teams, integrating these considerations from the early stages of a project can be significantly more efficient than addressing them once the product has already been developed.
This can be particularly valuable for companies managing products across several markets, where European packaging requirements need to be integrated into a broader international product strategy.
PPWR and new cosmetic product development
The PPWR will also influence decisions made during new cosmetic product development.
Packaging material, weight, individual components, recyclability and recycled content may all affect how packaging responds to current and future European requirements.
Packaging should therefore be considered not only from a design, functionality and consumer experience perspective, but also in terms of sustainability and regulatory compliance.
Integrating these considerations from the beginning of a development project can help reduce future modifications and facilitate product launches in the European market.
Working with a cosmetic manufacturer experienced with PPWR requirements can also help integrate packaging considerations from the early stages of product development.
Why should cosmetic companies prepare for the PPWR now?
The PPWR is being implemented progressively, but reviewing a complete packaging portfolio can take time.
For companies with multiple SKUs or products sold across different countries, the process may involve numerous packaging specifications and suppliers.
Starting early allows companies to:
- Review packaging across their EU portfolio.
- Identify available and missing supplier information.
- Detect potential documentation gaps.
- Coordinate with manufacturers and packaging suppliers.
- Consider PPWR requirements in upcoming developments.
- Plan potential packaging changes without disrupting launch schedules.
PPWR preparation should therefore be viewed as a supply-chain and product-development process, rather than simply a regulatory task.
Cosmewax: your cosmetic manufacturing partner for the European market
At Cosmewax, we develop and manufacture cosmetics for brands and retailers operating across international markets.
With manufacturing facilities in Spain and extensive experience working with international customers, we combine cosmetic product development, manufacturing and packaging management within a single industrial partner.
As a cosmetic manufacturer preparing for PPWR requirements, Cosmewax is working to integrate the new European packaging requirements into our processes and support customers with relevant information related to the packaging used for the products we manufacture.
Whether you are already established in Europe or developing products for the EU as part of a broader international strategy, working with an experienced European cosmetic manufacturer can help integrate packaging requirements from the early stages of product development.
If you are looking for a manufacturing partner for your next cosmetic project, our team can help you develop and manufacture products for the European and international markets.
Contact Cosmewax to discuss your next cosmetic manufacturing project.
Frequently Asked Questions about PPWR and cosmetics
Does the PPWR apply to cosmetic products?
The PPWR applies to packaging placed on the European Union market, including packaging used for cosmetic products. The specific obligations depend on the packaging and the role of each economic operator within the supply chain.
Does the PPWR apply to companies outside the EU?
Companies established outside the European Union may also be affected when their products and packaging are placed on the EU market. The specific responsibilities depend on how the products enter the European market and the role of the different economic operators involved.
What does the PPWR mean for cosmetic packaging?
The PPWR introduces requirements covering areas including packaging recyclability, minimisation, recycled content for certain plastic packaging, labelling, technical documentation and conformity assessment.
When does the PPWR apply?
Regulation (EU) 2025/40 entered into force on 11 February 2025 and generally applies from 12 August 2026. Some individual requirements have later implementation dates.
What packaging documentation will cosmetic companies need?
The required documentation depends on the packaging and applicable obligations. The PPWR establishes requirements concerning technical documentation, conformity assessment and the EU Declaration of Conformity, as well as information-sharing obligations throughout the supply chain.
How can Cosmewax support cosmetic brands with PPWR requirements?
As a European cosmetic manufacturer familiar with PPWR requirements, Cosmewax can support brands by integrating packaging considerations into product development, coordinating relevant information with packaging suppliers and providing information related to the packaging used for the products we manufacture.
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